Managing Safe Work Permits

What is a “Safe Work Permit”? A Safe Work Permit (SWP) is a WRITTEN document which SPECIFICALLY DEFINES THE WORK to be done AND the SPECIFIC PRECAUTIONS to be taken. We MUST recognize that a SWP is merely an ADMINISTRATIVE CONTROL and will ONLY bring the level of safety desired when the permit-to-work system is DEVELOPED, IMPLEMENTED, and MANAGED properly!

What is a “SWP Management System”? A Safe-Work-Permit Management System is a FORMAL - WRITTEN MANAGEMENT SYSTEM used to control certain types of work that are considered… NON-ROUTINE, and/or present POTENTIAL SERIOUS HAZARDS, and/or take place in POTENTIALLY HAZARDOUS WORK LOCATIONS

When is a Safe-Work-Permit needed? A SWP is needed when HAZARDOUS WORK ACTIVITY can ONLY be carried out if normal safeguards (i.e. written and approved procedures) are NOT in place to MANAGE THE RISKS associated with the work or when NEW HAZARDS are introduced/ created by the work. Examples are: Line Breaking/Opening Process Excavating/Trenching Contractor Work PRCS Entry Hot Work Live electrical work Working @ Heights

Why is there a need for a management system? A safety survey conducted by a safety agency showed that 1/3 of all accidents in the chemical industry were maintenance-related. The largest single cause being A LACK OF, OR DEFICIENCY in, SAFE-WORK-PERMIT-SYSTEMS 2/3 of companies were NOT CHECKING safety systems adequately 2/3 of safe work permits did not adequately IDENTIFY KNOWN AND POTENTIAL HAZARDS 1/3 of permits were UNCLEAR ON WHAT PPE was required for the specific task(s) 1/4 of permits did not deal adequately with FORMAL HAND-BACK OF EQUIPMENT/AREA once maintenance work had finished In many cases little thought had been given to permit form design Source: UK’s Health & Safety Executive (HSE)

Regulatory Requirements Some OSHA standards and Consensus Standards REQUIRE “safe work permit(s)” for specific hazardous work activities: Entering Permit Required Confined Spaces Welding, Cutting, Brazing (e.g. HOTWORK) Live Electrical Work (NFPA 70E) BEST PRACTICES also suggest that other HIGH HAZARD ACTIVITIES be managed via a “safe work permit” Line Break/Process Opening* (PSM/RMP) Lockout/Tagout (LOTO) Cranes (Critical Lifts) Lifting personnel Exceeding 75% capacity Lifting over LIVE PSM/RMP processes Excavation/Trenching

Permit Required Confined Spaces (PRCS) 1910.146 (e) Permit system Before entry is authorized, the employer shall document the completion of measures required by paragraph (d)(3) of this section by preparing an entry permit. PERMIT SYSTEM means the employer's WRITTEN PROCEDURE for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.

Opening process equipment or piping Process Safety Management (and RMP) 1910.119(f)(4) The employer shall DEVELOP and IMPLEMENT safe work practices to provide for the CONTROL OF HAZARDS during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by support personnel LINE BREAKING means the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.

Hot Work Permit - PSM/RMP and Grain Handling The implementation of a PERMIT SYSTEM for hot work is intended to assure that employers maintain control over operations involving hot work and to assure that employees are aware of and utilize appropriate safeguards when conducting these activities. … It should be noted that the permit is not a record, but is an AUTHORIZATION of the employer certifying that certain safety precautions have been implemented prior to the beginning of work operations.

1910.333(c) and NFPA 70E Electrical Safety Related Work Practices 130.2(B) Energized Electrical Work Permit. 130.2(B)(1) When Required. When energized work is permitted in accordance with 130.2(A), an energized electrical work permit shall be required under the following conditions: (1) When work is performed within the restricted approach boundary (2) When the employee interacts with the equipment when conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists

CONTRACTORS & PSM/RMP Process(s) 1910.119(f)(4)(iv) The employer shall DEVELOP and IMPLEMENT safe work practices … to CONTROL the ENTRANCE, PRESENCE and EXIT of contract employers and contract employees in covered process areas. A PERMIT SYSTEM or work authorization system for these activities would also be helpful to all affected employers. The use of a WORK AUTHORIZATION SYSTEM keeps an employer informed of contract employee activities, and as a benefit the employer will have better coordination and more management control over the work being performed in the process area.

Best Practices Excavation/Trenching Working @ Heights Cranes/Aerial Lifts LOTO

Reality in PSM/RMP Covered Process(s) A Contractor installing welded pipe in a “pipe rack” within a PSM/RMP covered process may require them to be part of Contractor Work Permit LOTO Permit, Line Break Permit, Hot Work Permit Aerial Lift /Working @ Heights Permit This work may REQUIRE five (5) SEPARATE work permits, often times issued by different individuals. LAYERS of [ADMINISTRATIVE] PROTECTION!

Developing, Implementing, Managing a Safe Work Permit Management System

Step #1 - DEFINE the scope Establish which activities will be “PERMITTED” activities Consider Regulatory Requirements and Best Practices Establish ownership of EACH PERMIT to ensure permit is 100% compliant with respect to CONTENT

STEP #2 – DEFINE “competency” Establish WHO can be a “PERMIT ISSUER/APPROVER” DEFINE the SKILLS, EXPERIENCE, and KNOWLEDGE for EACH SAFE WORK PERMIT Realize that being competent to issue one type of permit in one area does NOT make one competent in all permits in all areas! Keep regulatory requirements in mind

STEP #3 – Develop TRAINING programs DEVELOP training program(s) for EACH Permit Include TESTING w/ Pass/Fail limits Include REQUIRED MINIMUM REFRESHER frequencies (i.e. annual, every 3 years, etc.) Refresher frequencies may NOT be the same for all SWPs Include other triggers for REFRESHER training (such as failing audit results) Training programs should include a PROBATIONARY PERIOD where students issue permits UNDER TRAINED APPROVERS MOST IMPORTANT – permit training needs to explain ALL permit requirements and WHY they are what they are (e.g. why 35’ on HW permits?)

STEP #4 – MANAGE/MEASURE Permits LIMIT the # of permits issued in each area/unit at same time - CONTROL RISKS More SWPs issued = HIGHER RISKS Most facilities have limited ERT capabilities to respond (Fire/HAZMAT/Rescue) Hotwork Line Break/Process Openings PRCS Entries CRITICAL during Shutdowns/Outages Site emergency CANCELS/VOIDS ALL SWPs

Step #5 – Audit Permits FIELD AUDITS are CRITICAL Permit(s) issued properly? Person “authorized” Permit completely filled out Personnel working under permit properly? Working within scope of work? Working within the permitted area? Personnel wearing required PPE? Personnel understand emergency protocols?

Step #5 – Audit Permits DESK-TOP AUDITS are CRITICAL Permit(s) ISSUED properly? Permits CLOSED properly? KEEP SCORE! Trend your findings

Step #6 – IMPROVE process Based on data from the field audits and desk-top audits DEVELOP an IMPROVEMENT PLAN Plan may include: Revising program(s) and permit(s) Revising “competency” for authorizers Retraining authorizers Retraining receivers

Summary STEP 1 – DEFINE the SCOPE of your SWP mgt system STEP 2 – DEFINE COMPETENCY of Permit Approvers STEP 3 – Develop TRAINING PROGRAM STEP 4 – MANAGE permits DAILY STEP 5 – AUDIT, AUDIT, AUDIT, AUDIT and then AUDIT! STEP 6 – IMPROVEMENT PLAN based on data from audits